Wright v. Rockefeller
Encyclopedia
Wright v. Rockefeller, 376 U.S. 52
(1964), was a case in which the Supreme Court of the United States
held that in cases involving allegations of improper racial gerrymandering, where the evidence was "equally, or more, persuasive" that racial considerations had not motivated the State Legislature, the Court will give deference to the findings of the District Court.
, Eighteenth
, Nineteenth
, and Twentieth
Congressional Districts
in Manhattan
brought suit against New York state officials, including then Governor Nelson Rockefeller
, in the United States District Court for the Southern District of New York
challenging the constitutionality of the portion of New York's 1961 congressional apportionment statute which defined the four districts. The District Court permitted Congressman Adam Clayton Powell, who represented the Eighteenth District, along with several other New York County officials, to intervene as defendants supporting the constitutionality of the statute. The appellants claimed that apportionment statute deprived them of rights guaranteed by the Due Process and Equal protection portions of the Fourteenth Amendment and by the Fifteenth Amendment, which prohibit the government from denying or abridging the right to vote on account of race, color, or previous condition of servitude. Specifically, they claimed that the statute "establish[ed] irrational, discriminatory and unequal Congressional Districts in the County of New York and segregat[ed] eligible voters by race and place of origin."
The case was heard by a three judge panel of the District Court. Appellants presented maps, statistics, and other evidence demonstrating that African-Americans and Puerto Ricans comprised 86.3 per cent of the Eighteenth District, 28.5 per cent of the Nineteenth District, 27.5 per cent of the Twentieth District, but only 5.1 per cent of the Seventeenth District. A majority of the District Court panel found that appellants had not made out their case. One judge concluded that "no proof was offered by any party that the specific boundaries created by [the statute] were drawn on racial lines or that the Legislature was motivated by considerations of race, creed or country or origin in creating the districts." One judge dissented, viewing the evidence as "tantamount for all practical purposes, to a mathematical demonstration" that the legislation was "solely concerned with segregating" white voters from non-whites.
wrote for the majority, and was joined by 6 other justices, including Justice Harlan
, who also wrote a concurring opinion. Justices' Douglas and Goldberg each wrote dissenting opinions, and each joined the others opinion.
, a case that had also been decided that day.
, where racial gerrymandering was used to deprive African Americans on the right to vote. Douglas argued that though the right to vote was not being deprived, the redistricting was concentrating minority voters in particular districts and excluding them from others.
Douglas recited the relevant facts, and concluded that "[t]he record strongly suggests that these twists and turns producing an 11-sided, step-shaped boundary between the Seventeenth and Eighteenth Districts were made to bring into the Eighteenth District and keep out of the Seventeenth as many Negroes and Puerto Ricans as possible." Although he admitted that the District Court had not made such a finding, Justice Douglas concluded that, absent any rebuttal or challenge by the State, the only inference that could be drawn from the facts was that it was "not possible to say 'that race is irrelevant to districting.'"
Douglas next addressed the argument advanced by the intervening parties that the districting plan was beneficial to minorities, because it allowed minority politicians an advantage in heavily minority districts. Douglas rejected this argument, referring to it as the theory of "separate but better off," and writing "[t]he fact that Negro political leaders find advantage in this nearly solid Negro and Puerto Rican district is irrelevant to our problem. Rotten boroughs were long a curse of democratic processes. Racial boroughs are also at war with democratic standards."
Finally, Douglas compared the situation in the Manhattan districts to the Electoral Register System that the British
instituted in India
, and was also used in Lebanon
. Under that system, constituencies were separated by religion. Douglas wrote that "Racial electoral registers, like religious ones, have no place in a society that honors the Lincoln
tradition — 'of the people, by the people, for the people.'" Such a system, Douglas argued, "is a divisive force in a community, emphasizing differences between candidates and voters that are irrelevant in the constitutional sense."
Case citation
Case citation is the system used in many countries to identify the decisions in past court cases, either in special series of books called reporters or law reports, or in a 'neutral' form which will identify a decision wherever it was reported...
(1964), was a case in which the Supreme Court of the United States
Supreme Court of the United States
The Supreme Court of the United States is the highest court in the United States. It has ultimate appellate jurisdiction over all state and federal courts, and original jurisdiction over a small range of cases...
held that in cases involving allegations of improper racial gerrymandering, where the evidence was "equally, or more, persuasive" that racial considerations had not motivated the State Legislature, the Court will give deference to the findings of the District Court.
Factual and Procedural Background
Appellants, a group of citizens and registered voters in the SeventeenthNew York's 17th congressional district
New York's 17th Congressional District is a congressional district for the United States House of Representatives located in Southern New York. It encompasses portions of the Bronx, Westchester County, and Rockland County...
, Eighteenth
New York's 18th congressional district
The 18th Congressional District of New York is a congressional district for the United States House of Representatives in the northern suburbs of New York City. It includes most of Westchester County and part of Rockland County. It includes Larchmont, Mamaroneck, New Rochelle, Ossining, the Town of...
, Nineteenth
New York's 19th congressional district
United States House of Representatives, New York District 19 is located in the southern part of the state of New York. District 19 lies north of New York City and is composed of parts of Dutchess, Orange, Rockland, and Westchester Counties, in addition to the entirety of Putnam County.District 19...
, and Twentieth
New York's 20th congressional district
The 20th Congressional District of New York is a congressional district for the United States House of Representatives in eastern New York. It includes all or parts of Columbia, Dutchess, Delaware, Essex, Greene, Otsego, Rensselaer, Saratoga, Warren, and Washington counties. It includes the...
Congressional Districts
Congressional district
A congressional district is “a geographical division of a state from which one member of the House of Representatives is elected.”Congressional Districts are made up of three main components, a representative, constituents, and the specific land area that both the representative and the...
in Manhattan
Manhattan
Manhattan is the oldest and the most densely populated of the five boroughs of New York City. Located primarily on the island of Manhattan at the mouth of the Hudson River, the boundaries of the borough are identical to those of New York County, an original county of the state of New York...
brought suit against New York state officials, including then Governor Nelson Rockefeller
Nelson Rockefeller
Nelson Aldrich Rockefeller was the 41st Vice President of the United States , serving under President Gerald Ford, and the 49th Governor of New York , as well as serving the Roosevelt, Truman and Eisenhower administrations in a variety of positions...
, in the United States District Court for the Southern District of New York
United States District Court for the Southern District of New York
The United States District Court for the Southern District of New York is a federal district court. Appeals from the Southern District of New York are taken to the United States Court of Appeals for the Second Circuit The United States District Court for the Southern District of New York (in case...
challenging the constitutionality of the portion of New York's 1961 congressional apportionment statute which defined the four districts. The District Court permitted Congressman Adam Clayton Powell, who represented the Eighteenth District, along with several other New York County officials, to intervene as defendants supporting the constitutionality of the statute. The appellants claimed that apportionment statute deprived them of rights guaranteed by the Due Process and Equal protection portions of the Fourteenth Amendment and by the Fifteenth Amendment, which prohibit the government from denying or abridging the right to vote on account of race, color, or previous condition of servitude. Specifically, they claimed that the statute "establish[ed] irrational, discriminatory and unequal Congressional Districts in the County of New York and segregat[ed] eligible voters by race and place of origin."
The case was heard by a three judge panel of the District Court. Appellants presented maps, statistics, and other evidence demonstrating that African-Americans and Puerto Ricans comprised 86.3 per cent of the Eighteenth District, 28.5 per cent of the Nineteenth District, 27.5 per cent of the Twentieth District, but only 5.1 per cent of the Seventeenth District. A majority of the District Court panel found that appellants had not made out their case. One judge concluded that "no proof was offered by any party that the specific boundaries created by [the statute] were drawn on racial lines or that the Legislature was motivated by considerations of race, creed or country or origin in creating the districts." One judge dissented, viewing the evidence as "tantamount for all practical purposes, to a mathematical demonstration" that the legislation was "solely concerned with segregating" white voters from non-whites.
Court's Decision
Four justices wrote opinions in this case. Justice BlackHugo Black
Hugo Lafayette Black was an American politician and jurist. A member of the Democratic Party, Black represented Alabama in the United States Senate from 1927 to 1937, and served as an Associate Justice of the Supreme Court of the United States from 1937 to 1971. Black was nominated to the Supreme...
wrote for the majority, and was joined by 6 other justices, including Justice Harlan
John Marshall Harlan II
John Marshall Harlan was an American jurist who served as an Associate Justice of the Supreme Court from 1955 to 1971. His namesake was his grandfather John Marshall Harlan, another associate justice who served from 1877 to 1911.Harlan was a student at Upper Canada College and Appleby College and...
, who also wrote a concurring opinion. Justices' Douglas and Goldberg each wrote dissenting opinions, and each joined the others opinion.
The majority decision
The Court began with a recitation of the relevant factual and procedural background, and then turned to first question presented in the statement, whether "appellants sustained their burden of providing that the portion of [the statute] which delineates the boundaries of the Congressional districts in Manhattan Island segregates eligible voters by race and place of origin in violation [of the Constitution]." The Court accepted the findings of the majority of the District Court that the appellants failed to prove that the New York Legislature was either motivated by racial considerations or in fact drew the districts on racial lines. The Court accepted that there may have been evidence which could have supported an inference that the Legislature was moved by racial considerations, but found that there was also evidence supporting the contrary inference that was "equally, or more, persuasive." The Court accepted the finding that appellants failed to demonstrate that the statute was "the product of a state contrivance to segregate on the basis of race or place of origin," and therefore upheld the District Court's decision.Harlan's concurring opinion
Justice Harlan joined the opinion of the Court, but wrote separately, in a paragraph long concurrence, to comment that he believed that this case was governed by entirely different principles than in Wesberry v. SandersWesberry v. Sanders
Wesberry v. Sanders, 376 U.S. 1 was a U.S. Supreme Court case involving U.S. Congressional districts in the state of Georgia. The Court issued its ruling on February 17, 1964. This decision requires each state to draw its U.S...
, a case that had also been decided that day.
Douglas' dissenting opinion
Justice Douglas dissented, arguing that the case raised a similar question to the issue raised in Gomillion v. LightfootGomillion v. Lightfoot
Gomillion v. Lightfoot, 364 U.S. 339 , was a United States Supreme Court decision that found an electoral district created to disenfranchise blacks violated the Fifteenth Amendment.- Decision :...
, where racial gerrymandering was used to deprive African Americans on the right to vote. Douglas argued that though the right to vote was not being deprived, the redistricting was concentrating minority voters in particular districts and excluding them from others.
Douglas recited the relevant facts, and concluded that "[t]he record strongly suggests that these twists and turns producing an 11-sided, step-shaped boundary between the Seventeenth and Eighteenth Districts were made to bring into the Eighteenth District and keep out of the Seventeenth as many Negroes and Puerto Ricans as possible." Although he admitted that the District Court had not made such a finding, Justice Douglas concluded that, absent any rebuttal or challenge by the State, the only inference that could be drawn from the facts was that it was "not possible to say 'that race is irrelevant to districting.'"
Douglas next addressed the argument advanced by the intervening parties that the districting plan was beneficial to minorities, because it allowed minority politicians an advantage in heavily minority districts. Douglas rejected this argument, referring to it as the theory of "separate but better off," and writing "[t]he fact that Negro political leaders find advantage in this nearly solid Negro and Puerto Rican district is irrelevant to our problem. Rotten boroughs were long a curse of democratic processes. Racial boroughs are also at war with democratic standards."
Finally, Douglas compared the situation in the Manhattan districts to the Electoral Register System that the British
United Kingdom
The United Kingdom of Great Britain and Northern IrelandIn the United Kingdom and Dependencies, other languages have been officially recognised as legitimate autochthonous languages under the European Charter for Regional or Minority Languages...
instituted in India
India
India , officially the Republic of India , is a country in South Asia. It is the seventh-largest country by geographical area, the second-most populous country with over 1.2 billion people, and the most populous democracy in the world...
, and was also used in Lebanon
Lebanon
Lebanon , officially the Republic of LebanonRepublic of Lebanon is the most common term used by Lebanese government agencies. The term Lebanese Republic, a literal translation of the official Arabic and French names that is not used in today's world. Arabic is the most common language spoken among...
. Under that system, constituencies were separated by religion. Douglas wrote that "Racial electoral registers, like religious ones, have no place in a society that honors the Lincoln
Abraham Lincoln
Abraham Lincoln was the 16th President of the United States, serving from March 1861 until his assassination in April 1865. He successfully led his country through a great constitutional, military and moral crisis – the American Civil War – preserving the Union, while ending slavery, and...
tradition — 'of the people, by the people, for the people.'" Such a system, Douglas argued, "is a divisive force in a community, emphasizing differences between candidates and voters that are irrelevant in the constitutional sense."